Manufacturing processes are a key source of faults in complex hardware systems. Minimizing this impact of manufacturing uncertainties is one way towards achieving fault tolerant systems. By treating manufacturing as a stochastic development process, we characterize some of the constraints limiting the levels of robustness that can be achieved with evolution. The analysis is by introducing a novel abstraction of development as a strategic decision-making process. Using this abstraction to analyze a toy system that simulates a process of noisy assembly, we compare the maximum robustness achievable with adaptive and non-adaptive developmental strategies. Even in this highly simplified setup, the optimal adaptive and non-adaptive genotypes reveals a significant empirical difference in their robustness characteristics. This suggests that the choice of developmental strategy and the properties of the setup are major constraints on the robustness achievable, even prior to evolution-related considerations.